Explaining the reasons for his request, Modi said, "The requests are not motivated by any personal grudge but with the sole intention that whatever is the outcome of the present proceedings, the process leading to such decision should be fair and proper, thereby rendering the same unimpeachable."

Facing charges of financial irregularities that include allegations of bid-rigging and proxy investment, Modi explained why he wanted Manohar to stay out of the decision-making process.

"I am constrained to prefer the present application for your kind consideration that you may consider recusing yourself from participating any further in the proceedings relating to complaint and show cause notice as your participation in the proceedings would tantamount to being a judge, witness and a potential co-notice in these very proceedings," Modi said.

The suspended IPL chief went on to say that he had refused to accept Rendezvous Sports World's bid for Kochi franchise since it came late and claimed that Manohar decided to cancel the first bid process after the incident.

"I declined to accept the same, saying it was beyond time. You, however, asked me to accept the bid. You seemed to be under extreme pressure to ensure that the late bid be included in the bidding process," Modi wrote.

"I had pointed out that the whole process of cancellation was illegal, but then it seems that you were committed and hence under tremendous pressure to cancel the bid," Modi wrote.

Modi said Manohar was in frequent touch with former minister Shashi Tharoor, who was backing the Kochi bid.

"I appreciate that due to (the) involvement of a cabinet minister you had to do things which knowing you I believe you would not do in the normal course," he said.

His other request was to bar BCCI secretary and co-owner of Chennai Super Kings (CSK) N Srinivasan from participating in the proceedings.

Calling Srinivasan "instrumental in sponsoring complaints" against him, Modi said he would like to cross-examine him in the enquiry.

Modi said Srinivasan would have an axe to grind against him for various reasons.

"I have sufficient cause to apprehend bias. This stems from the manner in which I have consistently frustrated and exposed his attempts at misusing his position as secretary," he added.

Modi alleged Srinivasan had handpicked umpires from Chennai to oversee CSK matches before he intervened.

"This constituted a clear attempt at umpire fixing/match-fixing. Upon my coming to know of this I objected to the same and removed them in the interest of the League," Modi said.

"Since I have been opposed to his manner of functioning from the very inception, it is obvious that to protect his position, the Hon Secretary has good reasons not just to defame me but also to find me guilty of these imaginary wrongdoings alleged in the show cause notice," Modi wrote.

Modi said BCCI members, other than those in the IPL Governing Council, and persons with judicial experience -- like former Chief Justice of India -- maybe included in the panel.